Hon’ble National Green Tribunal - Ministry of ...envfor.nic.in/sites/default/files/Final draft...
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JOINT INSPECTION REPORT
(25.04.2017)
OF
THE SPECIAL INSPECTION COMMITEE
Constituted by
Hon’ble National Green Tribunal
(Order dated 24th April, 2017)
IN THE MATTER OF
M.C. MEHTA VS. UNION OF INDIA
[O.A. NO. 200/2014]
- Submitted by-
Shri R. N. Jindal, Director Ministry of Environment, Forest and
Climate Change
Member Secretary Uttar Pradesh Pollution Control
Board
Shri Sundeep, Director (T-II) National Mission for Clean Ganga
Member Secretary Central Pollution Control Board
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JOINT INSPECTION REPORT OF THE SPECIAL INSPECTION COMMITTEE
CARRIED OUT ON 25.04.2017
IN THE MATTER OF M.C. MEHTA VS. UNION OF INDIA [O.A. NO. 200/2014] ON
THE DIRECTIONS OF HON’BLE NGT DATED 24.04.207
1. Subject Matter
Matter: M.C. Mehta Vs. Union of India, O.A. No. 200/2014 – C.W.P. 3727/1985.
Subject: Prevention and Control of Pollution of River Ganga – Segment B – Phase I,
Haridwar to Kanpur downstream (Unnao).
2. Order of Hon’ble NGT dated 24.04.2017
The Hon’ble Tribunal in the said matter passed the following directions on 24.04.2017
which is placed as under:-
Consequently, we hereby constitute a special inspection team consisting of
Member Secretary, Central Pollution Control Board; Mr. Sandeep, Director
(Tech.), National Mission for Clean Ganga; Mr. R.N. Jindal, Director, Ministry of
Environment, Forest and Climate Change and Member Secretary, Uttar Pradesh
Pollution Control Board or his nominee being a senior most officer of the Board.
This Committee shall inspect the industries tomorrow as follows:-
1. The industries will continue to operate to their optimum capacity and would keep
all their records ready without default.
2. In the light of above, if any industry is found to be avoiding compliance of
directions and to be inoperative, the inspection team shall shut down the same
forthwith and it would be sealed by the Committee.
3. The Committee shall be provided all assistance and SHO of the concerned area
is also directed to provide Police Assistance to them for proper execution of this
order.
4. The inspecting team shall prepare complete and comprehensive report, to be
specific, on the following:-
a) What is the source of water used by the industry and its quantity,
availability, water meters etc.
b) Whether the unit are ZLD. ZLD means they are not discharging any
effluent, either on the land or in the waterbody or at any other place for that
matter. They should be able to either not discharge a drop of liquid or
recycle the same entirely without releasing thereto any effluent.
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c) Whether adequate ETPs have been provided and were found to be
functional or not at the time of inspection, including its adequacy;
performance; and its records thereof.
d) The Committee would collect effluent samples at the inlet and outlet of
the ETP and at the point of discharge, at the ultimate end.
e) Whether there is separate provision of Energy Meter for the ETP/ZLD.
f) Whether there are online monitoring system installed and operative and
if so connected to which authority, calibration/validation thereof;
g) Whether water flow-meter have been installed.
h) The inspection team shall also analyze the effluent quality at the end of
the drain as well as at the point where Mahua starts.
i) The samples shall also be collected from the drain nearest to the industrial
unit.
j) The committee may also examine the Ambient Air Quality in that area.
k) Whether any of the industries have a by-pass mechanism provided in the
factory, even if it has been now closed or groundwater injection system.
l) The inspection shall also verify the agricultural areas used for disposal of
effluent of the industries.
3. The Committee and its execution
In compliance of the directions of Hon’ble NGT, the Committee consisting of Member
Secretary, Central Pollution Control Board; Mr. Sundeep, Director (Tech.), National
Mission for Clean Ganga; Mr. R.N. Jindal, Director, Ministry of Environment, Forest and
Climate Change and Member Secretary, Uttar Pradesh Pollution Control Board visited
the area called, Gajraula on 25.04.2017 and inspected the following industries-
1. M/s ASP Sealing Product Ltd., Gajraula
2. M/s. Jubilant Agri & Consumer Products Ltd.(Fertilizer Unit), Bharatigram,
Gajraula, District – Amroha, UP
3. M/s. Jubilant Life Sciences Ltd. (Chemical Unit I), Bharatigram, Gajraula, District
– Amroha, UP
4. M/s. Jubilant Agri & Consumer Products Ltd. (Polymer unit), Bharatigram,
Gajraula.
5. M/s. Jubilant Life Sciences Ltd. (Chemical Unit II).Bharatigram, Gajraula, District
– Amroha, UP
6. M/s Jubilant Life Sciences Ltd. (Distillery Unit), Bharatigram, Gajraula, District –
Amroha, UP
7. M/s Insilco Ltd., A-5, UPSIDC Industrial Area, Gajraula, UP
8. M/s. Kamakshi Papers Pvt. Ltd., Gajraula
9. M/s Dairy India Private Ltd. Gajraula, Amroha, UP
10. M/s. Kaushambi Papers Mills Pvt. Ltd., Khasra No-138, Naipura Kadar,
Dhanaura, Gajraula, Amroha, UP
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The Committee focused and concentrated on the issues directed by the Hon’ble NGT
w.r.t. each industry. The Committee has also given due attention on the house-keeping,
drainage, maintenance of ETP, utilization and disposal of treated effluent, compost
making, effluent storages, utilization of groundwater for dilution purpose, solid / hazardous
waste management and the impacts of effluents on environment.
4. Collection of Samples
The Committee has collected samples from industries so inspected and samples have
been analyzed in CPCB lab for the parameters relevant to that particular industry.
The Committee has further collected, ground water samples for which the local farmers
made a reference during the visit. The samples have been analyzed in CPCB laboratory
(EPA recognized) following specified methods as per American Public Health Association
(APHA) and the guidelines / SoP certified by the National Accreditation Board for Testing
and Calibration Laboratories (NABL).
5. Industry-wise Inspection Reports
Altogether 10 industries were inspected by the Committee of which 9 are out of 12 units
mentioned and placed before Hon’ble Tribunal by the Learned Counsel of UPPCB. The
Industry-wise Inspection Reports are given in Annexure-I (Page 16 to 30).
Subsequent to the direction of Hon’ble NGT (dated 28.05.2017), two Senior Scientists of
CPCB along with official from NMCG, MoWR, RD & GR visited remaining 3 industries on
01.05.2017 namely:-
1. M/s. Coral News Prints, Gajraula, J P Nagar
2. M/s. Teva API India Ltd. A-2/1, A2/2, UPSIDC Industrial Area Gajraula
3. M/s. Umang Dairies Ltd. 3km. Hasanpur Road, Gajraula
The brief report of these units (without test report) is also given at Annexure – II (Page
31 to 33).
6. The Observations / Findings / Recommendations
The unit-wise observations / findings are summarized as under:-
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6.1 M/s ASP Sealing Product Ltd., Gajraula
Observation(s):
(i) This unit is an ancillary unit for automobile industries and their products is
rubber sealing.
(ii) Industry uses water in boiler, cooling of extruders, coolants along with
lubricant for grinding / cutting operations as a result, generating estimated
quantity of effluent, around 0.5 KLD.
(iii) Effluent is stored in a holding tank but, near the tank inundated water with
oily scum was observed.
(iv) The test report of sample collected from holding tank indicates the results
as under:-
pH : 7.22
COD : 1599 mg/l (250 mg/l)
BOD : 389 mg/l (30 mg/l)
TSS : 585 mg/l (100 mg/l)
Oil & Grease : 904 mg/l (10 mg/l)
Recommendation(s):
1. The industry shall install effluent treatment plant (ETP) to meet the stipulated
standards.
2. Treated water should be utilized for cooling and other low quality water
requirement purposes to reduce axillary water requirement.
3. Treated effluent should be properly utilized for gardening.
4. After polishing the effluent, effluent should go back for cooling purpose within the
industry thereby reducing the ground water consumption.
5. The oil containers and other solid waste materials needs to be handled as per the
provision of Hazardous Waste Rules, after characterization and found applicable.
Else, should be managed as per the direction of UPPCB to avoid any littering, open
burning or in-secured land disposal to avoid contamination of land and/or around
or surface water bodies.
6.2 TO 6.6 M/S JUBILANT LIFE SCIENCES LIMITED, GAJRAULA (COMPLEX),
The Jubilant Group of industries are situated in an integrated complex consisting of
a) Coal based Captive CO-generation Power Plant (48 MW capacity)
b) Molasses based Distillery (305 KLD – Ethyl Alcohol)
c) Chemical Unit 1 (Formaldehyde, Acetaldehyde, Ethyl Acetate, Acetic Acid, Acetic
Anhydride, etc,.) and
d) Chemical Unit 2
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e) Fertilizer Unit
f) Polymer unit
This industrial complex has common utility services catering to the auxiliary and process
support requirement such as:
1. Water Management System (DM Water, Process steam, Spent Solvent Recovery
systems)
2. Common Cooling Water blowdown effluent management system (CTRO) – 1200
KLD
3. Chemical Effluent Treatment Plant (CETP) – 700 KLD
4. Incinerators - 3 nos for Liquid – 288 KLD & 2 nos for Gaseous/Thermo Oxidiser
– 1500 kg
5. Secured landfill – 11000 MT
As informed by the unit representative, all units were operating with valid consent.
The unit wise findings are as below:
A. Captive Power Plant (48 MW or equivalent capacity)
The integrated chemical complex has a coal based co-generation power plant for its
captive requirement of power and steam. It has 2 x 90 TPH (High Pressure Boiler) for
turbine operation. The released low-pressure steam from turbine operation is used to
meet the process and heating requirements for the industrial units situated within the
industrial complex of Jubliant. There are 2 nos. Medium Pressure Boilers (24 TPH an 34
TPH) as a standby as reported.
Observation(s):
1. The power and steam supply to meet the requirement of all units/process in the
industrial complex are made from common facility – Captive Power Plant
2. The power plant is coal based facility and has power generation as well as steam
generation facility.
3. The boilers are equipped with ESP, however, the management and disposal of
bottom ash and fly ash is very poor.
4. No significant or considerable emission from boiler stack was visual observed.
5. The source of water for Captive Power Plant is Ground water,
6. Ambient air quality status within plant area as well as affected zone in the vicinity
of the plant was visually observed as very poor. Heavy cloud of fly ash dust arising
from the fly ash storage area was affecting the visibility within the industry
operation area.
7. Primary assessment based on the discussion with the plant officials revealed that
the fly ash is partially utilised and significant amount is stored in their identified
storage pond. However, huge dust was arising from the storage area. This was
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mainly due to lack of appropriate measures in place to control and prevent
resuspension of ash. This also reveal poor fly ash utilisation potential available
with the unit.
8. Wet fly ash pond is situated about 3 km from plant premises. Ash slurry is pumped
through a closed pipeline, but settled water recycle arrangement from the ash pond
was not found.
9. The provisions of Fly Ash management Rules 1999 (amended- 2016) is apparently
not complied with by the unit.
10. The percentage utilization of DM water against the installed capacity (88%) vis-à-
vis utilization of Power and Steam generation (Coal fired, slop fired and WHRB)
which is 58%, suggest that the unit is operating with low ratio of cycle, thereby
having higher water consumption.
11. Non-complying
Recommendation(s):
a. The unit shall have a robust and appropriate fly ash management system as per
the provision of fly ash rules
b. The unit shall install adequate number of dust suppression system at critically
identified locations, proper covering of bottom ash and fly ash in the pond, use ash
pond as ultimate option for storage, 3 months plan for fly ash utilisation, and
promotion and facilitation of brick/tiles manufacturing and other such uses facilities
through community entrepreneurship promotion.
c. The units shall use washed coal as per the MoEF notification
d. Proper ash management records shall be maintained and submitted to UPPPCB.
e. The unit shall be instructed to put continuous ambient air quality monitoring station.
f. The industry shall be directed to take a detail water audit of all its water and steam
intensive process including their associated utilities/auxiliary services in order to
identify the water conservation measures and submit corrective action plan for its
implementation to UPPCB.
6.2 M/s Jubiliant Life Sciences Ltd. (Distillery Unit)
(i) The Distillery was found operational at 120 KLD capacity against consented
capacity of 305 KLD (Ethyl Alcohol) and adopts both options of effluent treatment
acceptable by the CPCB
a. Bio-composting
b. Slop Incineration Approach
(ii) The unit claims to have infrastructure to achieve Zero Liquid Discharge (ZLD) by
combining both the options.
(iii) The spent wash is subjected to Bio-methanation process for recovery of energy.
The bio-methanated spent wash (BMSW) is sent to RO (1200 KLD) where
assuming 60% permeate is return to the process for molasses dilution and
remaining 40% is subjected for Multiple Evaporation (MEE) The MEE operates
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with an efficiency of 70%, i.e., 70% water is recovered and 30% slop generation
is stored for either Bio-composting or Slop boiler feed.
(iv) During the time of the visit, all effluent treatment facilities of the distillery Viz.
Reverse Osmosis, Multiple Effect Evaporator, Incinerator and Biocomposting
were in operation. The Reverse osmosis plant was operating close to its design
capacity (54 KL/Hr).
(v) MEE was operating at 40% of its installed capacity at the time of inspection, with
about 70% recovery.
(vi) Slop boiler unit was operating at 4 KL/Hr (100 KLD against installed capacity -
300 KLD). The ash from the Slope boiler is disposed to the fly-ash dump yard as
reported.
(vii) The Bio-composting facility has capacity to handle approximately (200 T/row x
110 rows x 3 rounds of 90 days each) = 66,000 MT of press mud per annum.
Assuming an average 1.5-1.8 m3 of MEE concentrate / Ton of press mud for final
bio-compost output, total consumption of MEE Concentrate will be approximately
1,18,800 cum per annum.
Considering 300 days of slope boiler feed operation, the total MEE reject
feed consumed is assessed as (300 days * 300 KLD) = 90,000 cum per annum.
So, total reject consumption facility available with the units is as below:
S.No Description KLD KLA (300 days)
A RO Feed capacity of BMSW 1200 3,60,000
B RO Reject generation (40% of 1200 KLD)
480 1,44,000
C MEE feed capacity 1600 4,80,000
D Remaining capacity of MEE after RO reject (1600 KLD – 480 KLD)
1120 3,36,000
E Reject generation from MEE (30% of 1600 KLD)
480 1,44,000
Therefore, even the unit has more capacity to utilise the MEE reject, the critical
capacity of the wastewater management system is that of MEE installed capacity,
which is 1600 KLD. The optimised feed consumption of Bio-Methanated Spent
Wash (BMSW) after considering RO reject (40% of feed) and remaining BMSW
works out as (A+D) – 1200 +1120 = 2320 KLD.
Assuming the Spent wash generation rate (Continuous process) of 12 Kl
per KL of alcohol production, the installed capacity for ZLD achievement through
RO + MEE + (Bio-composting/Slope Boiler) is equivalent to (2320/12) – 190 KLD.
The above calculation don’t includes other low strength wastewater
generated from the distillery process.
Therefore, it is observed that the available infrastructure acceptable to
achieve zero liquid discharge from distillery units is only for production of 190 KLD
instead of consented capacity of 305 KLD.
(viii) About 3 km away from the plant, there is a compost making yard which has been
covered with the shed. However, there was no immediate record shown on the
site relating to procurement of press-mud and utilization of spent wash.
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(ix) Further, the compost is reported to be given to the marketing companies. This is
also to submit that, prior to the selling of compost, the distillery is required to get
the compost samples analysed and execute marketing with proper marking /
specifications on the bags.
(x) The spent wash has been stored in the lagoon and its storage with huge quantity
is of serious concern to the Committee as its management.
(xi) As per the information provided, the bio-compost area is about 30 acres. Certain
portion about 3 acres have covered facility, to make it workable during monsoon
season. But, there is no provision made for storage of finished compost as per
the requirement of CPCB guidelines. However, shed for storage of Press Mud,
finished bio-compost, screening and bagging, facility are apparently not available
as per CPCB guidelines.
(xii) The unit has a line paccu lagoon of 44,000 cum to holding the MEE reject for use
in bio-composting. As reported, the lagoon has not been cleaned for last 5-6
years, and therefore considerable amount of accumulation sludge is there in the
pond, which has reduced its holding capacity. In absence of level reading staff,
the storage capacity utilised at the time of inspection could not be assessed.
As per CPCB regulatory provision, the holding capacity shall be not more
than 30 days of spent wash generation. Considering 305 KLD, the total holding
capacity allowed is about (305 KLD x 12 KL/KL x 30 days) = 109800 KLD against
the present 44,000 KL (40%). However, the lagoon is not protect (fencing) from
outsider trace passing, and having high risk of safety hazards/accident.
(xiii) No ground water monitoring Piezowell based on the ground water flow direction
was found near the lagoons or bio-composting plant, however, the unit
representative informed, that two such well are available. The details were not
provided during the visit.
(xiv) The industry on the spot could not provide the record on utilization of spent wash
in RO / MEE / SFB linking with spent wash generation and utilization in
corresponding processing unit.
(xv) Near the RO plant, huge flyash deposition was seen in the open ground which
incidentally got suspended in air due to sudden strong windy conditions. This has
shown the improper management of fly ash (from captive thermal power plant).
(xvi) It was also observed near compost / logoon area, the Committee apprehended
the spent wash and utilized compost was spread in the large area and was
levelled and covered with earth soil. It is felt that during rainy season the rain
water will seep through such area and add colour to the ground water (for quick
test, the sample of the ground where compost / spent was and soil was mixed,
the samples was taken in a plastic bottle and was filled with the water and the
colour obtained is shown in a plate / photo given in Annexure -III).
(xvii) Non-complying and subjected for regular monitoring and action plan to improve
conditions.
Recommendation(s):
a. The industry shall provide necessary infrastructure fat the bio-compost yard
as per the provisions of CPCB guidelines
b. The MEE reject storage lagoon (44000 cum) shall be divided with provision
of necessary safety and security measures.
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c. There shall be adequate number of groundwater monitoring well in and
around compost yard and the monitoring result shall be put in public
domain.
d. Inventory records of press mud, bio-compost and wastewater utilization
shall be maintained.
e. UPPCB shall modify the consented production capacity of the unit as per
the available operational infrastructure to meet the stipulated conditions.
6.3 M/s Jubilant Agro & Consumer Products Ltd.,(Fertilizer unit)
(i) It has been informed that the unit is recycling its effluent into the process
and no effluent are required to be disposed.
6.4 M/s. Jubiliant Life Sciences Ltd. (Chemical Unit I) and
6.5 M/s. Jubiliant Agri & Consumer Products Ltd. (Polymer unit)
(i) The effluent generated from the Chemical Plant Unit –I and Polymer unit is
treated at the Chemical Effluent Treatment Plant
(ii) There is no MoU between the different units having individual consent to operate
for contribution/conveying their effluent to the CETP. Therefore, the primary raw
water quality will be subjective and meeting the norms will be a major challenge.
Apart from the operational difficulties, it is difficult to take any action by the
regulatory body in case on non-compliance observed to the stipulated norms/
provisions as onus and obligation to meet the regulatory norms is not clear.
(iii) The CETP was found operational during the visit. Water samples from the inlet,
outlet and aeration tank – I was collected to assess the performance. Results
suggests MLSS concentration to be in acceptable range.
(iv) The hydraulic gradient line of the CETP was non-continuous; an essential
parameter to support is proper functioning. It suggest there is a design and/or
poor maintenance issue.
(v) The energy meter reading depicts the energy consumed; however, it is very
difficult to infer any conclusion on CETP operation status from the consumption
data, unless correlation of energy consumed and requirement is defined with a
7-day optimised operation of the CETP facilities.
(vi) The CETP is equipped with online effluent monitoring system and it needs to be
verified from the observed value during the field visit to assess the variation, if
any.
(vii) The treated wastewater is reported to be used for horticulture within the unit
area. There is no documentation / records maintained for the purpose. It needs
to be verified to ensure that there is no direct or in-direct discharge of such
treated water.
(viii) There was no irrigation plan to utilize treated effluent
(ix) Further the characteristics of inlet and outlet are as under:-
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Source pH TSS COD BOD MLSS
Inlet 3.26 142 2742 1732
Outlet 8.12 21 125 28
Aeration tank 1445
All the concentrations are expressed in mg/l except pH
(x) Non-complying with reference to function aspects of CETP and subject to
regular monitoring.
Recommendation(s):
a. All individual consented unit using the common facilities, (Cooling tower water
system, steam and CETP etc.) shall have a MoU and identify the ownership and
obligatory unit for compliance to stipulated norms. The same shall be considered
by UPPCB for issuance of consent to operate.
b. Water balance, steam balance, wastewater generation and return to common
system shall be studied in detail and thereafter a proper water balance report shall
be prepared. The report shall be submitted to UPPCB within a period of 3 months,
before onset of Monsoon. UPPCH shall consider the finding and appropriately
modify the consent condition with an objective to conserve groundwater and
reduce water consumption/ achieve ZLD.
c. Energy consumption and its correlation with the records of dedicated energy meter
for ETPs, Water Meters shall be carried out through a study over a period of 7 days
of optimized operation of ETP/CETP. This will help in inferring the energy
consumption and operational status of various component and overall
performance of CETP/ETP.
6.6 M/s. Jubiliant Life Sciences Ltd. (Chemical Unit II),
This unit manufactures Pyridine and its derivative fine chemical compounds including
Cyano Pryridine, Lutidine and Picoline. The committee could not visit this units, however,
the effluent from these units are recalcitrant in nature and doesn’t qualify for biological
treatment. The committee has not visited the process area of these units.
(i) The wastewater generated from these units are primarily non-biodegradable in
nature and difficult to be subjected for conventional biological based effluent
treatment plant. The recalcitrant nature of wastewater is subjected to thermal
process.
(ii) As reported, 3 numbers of liquid incinerator (288 KLD) for management of such
wastewater has been provided.
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6.7 M/s. Insilco Ltd., Gajraula
(i) This industry is involved in washing / processing of sand used in tyre
industries.
(ii) The industry generates effluent having high Total Dissolved Solid (TDS).
(iii) At the time of inspection the effluent being discharged and the collected outlet
sample shows TDS of 320 mg/l. However when the samples were picked-up
from the Bagad River where the effluent is being disposed indicated TDS of
11284 mg/l.
(iv) The industry is using around 2 MLD of groundwater for diluting of effluent to
achieve the standards of prescribed for SAR. Therefore, this industry should
essentially operate on ZLD system and by recovery of salt (Na2SO4) with any
appropriate system. In no case effluent be disposed in ambient environment.
(v) The characteristics of samples collected are as under:-
Sampling
locations
pH TDS (mg/l) SAR SO4-(mg/l) F-
(mg/l)
Inlet 7.17 11112 27.7 5480 4.44
Outlet 7.64 320 6.4 55 0.41
Pond 7.13 10448 34.6 5932 3.92
All the concentrations are expressed in mg/l except pH
(vi) Non-complying. To adopt ZLD
Recommendations;
a. The unit shall stop using fresh water dilution for reducing the SAR in order to
comply with the consent condition.
b. The treated water may be explore of its use at nearby industries so that the overall
stress on ground water in the area is reduced. This approach shall be through MoU
and consent of UPPCB.
6.8 M/s. Kamakshi Papers Pvt. Ltd. Gajraula
(i) This industry is utilizing waste paper for manufacturing newsprint paper.
(ii) The sludge drying beds were flooding. The industry reported that hard board
manufacturers could not lift this sludge which they use as raw material.
(iii) The results of the ETP are as under:-
Source TSS COD BOD
Inlet 761 474 113
Outlet 58 222 52
All the concentrations are expressed in mg/l except pH
(iv) The ETP shows higher value of BOD, COD, exceeding the prescribed limits
and the treated effluent are used in the process and applied on land for
irrigation purpose thereby not discharging.
(v) There is a bypass arrangement which should be sealed.
(vi) Non-complying – require to block by-pass and de-sludge
.
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6.9 M/s. Dairy India Pvt. Lid, Gajraula
(i) There ETP was operational and growth of algae in aeration tank indicated
improper function of the aeration tank.
(ii) The treated effluent is being claimed to be utilized for gardening. The
treated effluent shows higher value of BOD.
(iii) Permission from the CGWA is not available.
(vii) The results of the outlet sample collected from ETP are as under:-
Source pH TSS (mg/l) COD (mg/l) BOD (mg/l)
Inlet 4.35 1700 5344 1025
Outlet 8.40 37 142 53
(viii) Non-complying. Need to improve ETP functioning
6.10 M/s. Kaushambi Papers Mills Pvt. Ltd.
(i) Waste was strewed around the campus and was piled on the land claimed to be
owned by the unit.
(ii) Sludge was not properly stored and was found outside of the premises also.
(iii) Not operating due to mechanical fault.
7. Ambient Conditions
The special team has reached Gajraula and collected samples from the Bagad drain from
NH 24. The upstream of the drain was also traced and found to be dry before the
confluence of the industrial effluent from M/s Insilco Ltd., A-5, UPSIDC Industrial Area,
Gajraula, UP. The Bagad drain is also known as Barad river which is presently dry at
upstream of effluent disposal point of Insilco.
Dry Bagad drain before effluent disposal point from M/s Insilco Ltd
Samples collected from Bagad from the
bridge of NH-24
The analysis result of the samples collected from of the drains at NH-24 are as follows;
Source pH COD BOD TDS SAR NH3-N
Inlet 7.24 68 18 11284 29.9 BDL
All the concentrations are expressed in mg/l except pH
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Samples were also collected from the groundwater of the agriculture near the railway line
in between the Jubilant Industrial complex and the compost yard located indicates yellow
reddish colour and as per the villagers that was effect of previous practice of ferti-irrigation
of the M/s Jubilant Life Sciences Ltd. (Distillery Unit).
Analysis result of the ground water:
So
urc
e
pH
EC
TD
S
CO
D
BO
D
To
tal
Alk
a a
s
CaC
O3
To
tal
ha
rdn
e
ss
as
CaC
O3
Calc
iu
m a
s
Ca
C
hlo
rid
e
Su
lph
at
e
NO
2-N
NO
3-
NO
3
Flu
ori
d
e
Grou
nd
water
7.8 168
8
982 52 3 198 520 200 107 467 0.0
8
0.8
1
0.4
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Further, the poinwise information gathered by the committee on 13 points as per
order is given in Annexure – IV
Ground sampling point
Bagad River sampling point
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7. Conclusion:
The committee based on the inspection carried out in 9 units has reached to the following
conclusion:-
A. Ground water is the only source for all industries. The industries are not
having regards for ground water depletion or conservation. Water
conservation through high degree of recycle and reuse to minimize stress
on ground water were not observed.
B. Ground water recharging / rain water harvesting facilities were not
highlighted by the industries to the committee during the visit by nay of the
industries.
C. Permission from Central Ground Water Board were not available with the
industries at the time of visit.
D. All industries claim to use treated wastewater (Industrial/sewage) for
gardening / horticulture. There is no provision to deal with treated
wastewater during rainy season, therefore, there will be discharge during
rainy days, irrespective of land area available to the industries for irrigation.
Thereby, reuse and recycle of treated water within the industrial process,
utilities are essential with adequate storage facility to cater the storage
capacity during non-irrigation period.
E. The ground water sample collected from irrigated farm land was showing
colour (Pale yellow). This may be attributed to the past disposal practices
of spent wash in the contiguous area.
F. Records and data supporting Water balance, wastewater management,
compliance to the condition of consent issued by UPPCB were readily not
available with the industry.
G. Based on the available infrastructure and explained utilization mechanism
of treated wastewater management system of all industries, the committee
has strong apprehension that the units are not operating as Zero Liquid
Discharge (ZLD). The discharges are through unauthorized ways (to low
laying area etc.) under the cover of horticulture/ irrigation purposes.
H. Water balance report shall be submitted by all industries to UPPCB and
after verification, modification in operating consent condition may be made,
wherever found necessary.
I. The unit wise observation and associated recommendation(s) made by the
committee, shall be assessed by UPPCB and the industry and appropriate
measure shall be submitted as time bound action plan in form of Affidavit to
Honb’le NGT for its compliance, before the units are considered to start its
operation.
15
J. Community Monitoring system for close compliance verification shall be
considered with members selected by local authority consisting of locals,
farmers, eminent person of the area, subject and industry process experts,
representative from PCBs, Industry department. The finding and action
taken report shall be put on district administration website.
K. Physical outlet of ETPs indicate that regular operations are not ensured
which was evident due to maintenance of tanks, clafifier, sludge drying beds
etc.
8. Units visited on 01.05.2017
Pursuant to the order of Hon’ble Tribunal dated 28.05.2017, CPCB deputed two senior
scientist with UPPCB & NMCG to inspect 3 remaining units namely:- i) M/s. Umang Diary
Ltd., ii) M/s. Teva API Ltd. & iii) M/s. Coral Newsprint Ltd. At the time of writing the report,
analytical reports were awaited (will be ready by this week). However, the observation on
report is given on these units (Page No. 31- to 33)
16
Annexure-I
Details of the Individual Units
1. M/s. ASP Sealing Products Ltd.
Sl. No.
General Information
1. Name and address of the Industry M/s. ASP Sealing Products Ltd. A-7, UPSIDC Industrial Area, Gajraula, Dist. Jyotiba, Phule Nagar (UP) 244235
2. Contact Person & No. V K Updadhay
7055978605
3. Name of Product Sealing Product
4. Consent for air Valid upto : 31/12/17 (Copy enclosed)
Consent for water Valid upto : 31/12/17 (Copy enclosed)
5. Water Source Ground Water
CGWA Permission applied
6. Water consumption As per the copy of the logbook, the units is having two pumps and about 24 KLD water is withdrawn
7. Samples (from Storage Pit) analysis results
Parameters pH TSS (mg/l)
COD (mg/l)
BOD (mg/l)
Oil & grease (mg/l)
Samples from the units 7.22 585 1599 389 904
General discharge standards (land)
5.5-9.0 200 250 100 10
Photographs
Floor washing are not being collected properly
Observations:
Dry processing units, however, spillage of water was observed which is stored in sump
No treatment facility is available and untreated wastewater is being utilised for gardening.
The quality of wastewater sample collected from the units indicates non-compliance to BOD 389 mg/l, COD 1599 mg/l, Oil & Grease 904 mg/l and TSS, 585 mg/l.
Recommendation(s) 1. The unit should have a properly designed Effluent Treatment Plant (ETP) and comply with the
stipulated norms. 2. The water balance study shall be carried out and submitted to UPPCB for better transparency
in water management and imposing appropriate consent condition for operation.
17
2. M/s Jubiliant Life Sciences Ltd. (Distillery Unit)
1. Name of the unit and address M/s Jubiliant Life Sciences Ltd. (Distillery Unit), Bharatigram, Gajraula, District – Amroha, U.P,-244223
2. Name of the Contact person – Designation
Contact No.
C B Bhardwaj | Senior Vice President - Manufacturing (Unit Head) Mobile: 8126424555 FAX: 05924-252352
3. Year of Commissioning. 1982
4. Sector Private
5. Production details.
Products
Installed Prod. Cap.
Operating capacity
Alcohol
305 KLD
120 KLD (on the day of inspection).
6. Manufacturing process details & flow diagram
Flow Diagram
7. Raw material 1. Molasses : 14000 MT/day
8. Operational status Operating
B: Water Pollution and its Control:
1. Water Consumption (m3/day) Industrial 2500 KLD
Domestic 20 KLD
Make up water cooling tower
600 KLD
2. Sources water
Ground Water through borewell (NOC obtained from CGWA on 7/4/2017 for 3000 KLD)
3. Effluent Generation (m3/day) Spent wash 12 KL/KL of alcohol
4. Details of Spent Wash Management
Bio-methansation - RO (1200 m3 /day) MEE (1600 m3 /day) Bio compost/slope boiler
5. Status of consent
(Copy of the latest consent attached)
Consent for water Valid up to 31.12.2018
Consent for air Valid up to 31.12.2018
Spent Wash Management Bio-composting
1. Total area available for bio-composting [1ha=2.5 acres]
30 acres
2. Active area for bio compost preparation (acres)
30 acres
3. Facility for press mud storage Area for press mud storage -6 acres
4. Facility for bio compost storage 3 acres
5. Spent wash storage capacity (m3 ) One lagoon of capacity 44,000 m3
6. Arrangement for rainy season (Balance press mud storage facility, compost storage, shaded etc
Shed was constructed in 3 acres for rainy season. On the day of inspection whole area was filled with press mud/compost.
7. Adequacy of the system
a. Compost yard (lining, area, catch pits etc.
b. Special precaution for undigested spent wash
Composed yard is having 1000 M2shed.
Stored in Lined lagoon
18
utilization for making bio compost
c. Composting process and quality of finished product (spraying and churning arrangement and availability of pipe network)
d. Storage facility for press mud and finished product
e. Equipment and machinery (tractor, aerotiler, bagging machine , weighing machine loader, etc
Windrows method over a lined platform.
Both press mud and finished product were stored in an open area.
Aerotilers, trucks & JCB is available.
Bagging and weighing facility not available
Volume Reduction System
1. Filtration system
Design capacity of RO Plant /Nano filtration (feed rate, m3
, hr
RO plant is available with feed rate of 1200 m3 /d
2. Details of pre-treatment of effluent being fed to RO
Bio-methanation
3. Operating condition
a. Effluent feed rate (m3/hr) b. Operating pressure (kPa) c. Reject generation (m3/hr) d. Permeate (m3/hr)
52 m3/hr
29 cum/hr
23.8 m3/hr
4. Facility for permeate storage and its management(recycle/reuse/discharge)
Permeate is recycled to distillery for molasses dilution
5. Waste water generation Not assessed
6. Power consumption (kWhr) Not assessed
Evaporation system
1. 1.
Design capacity of evaporator
Number of effect in evaporator
1600 m3/day
5
2. Steam consumption (tonne/hr & temp in each effect)
250 KT/KT of feed
3. Generation of condensate (m3/hr) from each effect
70% of total feed
4. Normal uninterrupted operating time (hr)
20 days/month
5. Frequency of cleaning of plates / tubes
Once in 20 days
6. Waste water generated from cleaning operation (m3) and disposal system
200 KL/month and
7. Cleaning mechanism (manual / mechanical)
Mechanical
19
8. Management of concentrate (bio-composting/incineration)
Concentrate is used as a fuel in boilers and feed for bio-compost
Observations:
1. The Distillery was found operational at 120 KLD capacity against consented capacity of 305
KLD (Ethyl Alcohol) and adopts both options of effluent treatment acceptable by the CPCB
a. Bio-composting
b. Slop Incineration Approach
2. The unit claims to have infrastructure to achieve Zero Liquid Discharge (ZLD) by combining
both the options.
3. The spent wash is subjected to Bio-methanation process for recovery of energy. The bio-
methanated spent wash (BMSW) is sent to RO (1200 KLD) where 60% permeate is return to
the process for molasses dilution and remaining 40% is subjected for Multiple Evaporation
(MEE) The MEE operates with an efficiency of 70%, i.e., 70% water is recovered and 30%
slop generation is stored for either Bio-composting or Slop boiler feed.
4. During the time of the visit, all effluent treatment facilities of the distillery Viz. Reverse
Osmosis, Multiple Effect Evaporator, Incinerator and Biocomposting were in operation. The
Reverse osmosis plant was operating close to its design capacity (54 KL/Hr).
5. MEE was operating at 40% of its installed capacity at the time of inspection, with about 70%
recovery.
6. Slop boiler unit was operating at 4 KL/Hr (100 KLD against installed capacity - 300 KLD). The
ash from the Slope boiler is disposed to the fly-ash dump yard as reported.
7. The Bio-composting facility has capacity to handle approximately (200 T/row x 110 rows x 3
rounds of 90 days each) = 66,000 MT of press mud per annum. Assuming an average 1.5-1.8
m3 of MEE concentrate / Ton of press mud for final bio-compost output, total consumption of
MEE Concentrate will be approximately 1,18,800 cum per annum.
Considering 300 days of slope boiler feed operation, the total MEE reject feed
consumed is assessed as (300 days * 300 KLD) = 90,000 cum per annum.
So, total reject consumption facility available with the units is as below:
S.No Description KLD KLA (300 days)
A RO Feed capacity of BMSW 1200 3,60,000
B RO Reject generation (40% of 1200 KLD)
480 1,44,000
C MEE feed capacity 1600 4,80,000
D Remaining capacity of MEE after RO reject (1600 KLD – 480 KLD)
1120 3,36,000
E Reject generation from MEE (30% of 1600 KLD)
480 1,44,000
Therefore, even the unit has more capacity to utilise the MEE reject, the critical capacity of
the wastewater management system is that of MEE installed capacity, which is 1600 KLD.
The optimised feed consumption of Bio-Methanated Spent Wash (BMSW) after considering
RO reject (40% of feed) and remaining BMSW works out as (A+D) = 1200 +1120 = 2320 KLD.
Assuming the Spent wash generation rate (Continuous process) of 12 Kl per KL of
alcohol production, the installed capacity for ZLD achievement through RO + MEE + (Bio-
composting/Slope Boiler) is equivalent to (2320/12) = 190 KLD. (As per charter spent
wash generation is 8-12 KL/Kl of alcohol production)
The above calculation don’t includes other low strength wastewater generated from
the distillery process.
Therefore, it is observed that the available infrastructure acceptable to achieve zero
liquid discharge from distillery units is only for production of 190 KLD instead of consented
capacity of 305 KLD.
20
8. As per the information provided, the bio-compost area is about 30 acres. Certain portion about
3 acres have covered facility, to make it workable during monsoon season. But, there is no
provision made for storage of finished compost as per the requirement of CPCB guidelines.
However, shed for storage of Press Mud, finished bio-compost, screening and bagging, facility
are apparently not available as per CPCB guidelines.
9. The unit has a line paccu lagoon of 44,000 cum to holding the MEE reject for use in bio-
composting. As reported, the lagoon has not been cleaned for last 5-6 years, and therefore
considerable amount of accumulation sludge is there in the pond, which has reduced its
holding capacity. In absence of level reading staff, the storage capacity utilised at the time of
inspection could not be assessed.
As per CPCB regulatory provision, the holding capacity shall be not more than 30 days
of spent wash generation. Considering 305 KLD, the total holding capacity allowed is about
(305 KLD x 12 KL/KL x 30 days) = 109800 KLD against the present 44,000 KL (40%).
However, the lagoon is not protect (fencing) from outsider trace passing, and having high risk
of safety hazards/accident.
10. No ground water monitoring Piezowell based on the ground water flow direction was found
near the lagoons or bio-composting plant, however, the unit representative informed, that two
such well are available. The details were not provided during the visit.
11. The industry on the spot could not provide the record on utilization of spent wash in RO / MEE
/ SFB linking with spent wash generation and utilization in corresponding processing unit.
12. Near the RO plant huge fly ash deposition was seen in the open ground which inadvertently
got suspended in air due to sudden strong windy conditions. This has shown the improper
management of fly ash (from captive thermal power plant).
13. Further the compost is reported to be given to the marketing company for further movement.
This is also to submit that prior to the selling of compost, the distillery is required to get the
compost samples analyzed and execute marketing with proper marking / specifications on the
bags.
14. It was also observed that the near the compost / logoon area, the committee apprehended the
spent was and utilized compost was spread in the large area and was levelled and covered
with earth soil. The committee felt that during rainy season the rain water will seep through
such area and may cause coloration in the ground water (for quick crude test and following
crude test the surface of the ground where compost / spent was and soil was mixed and was
taken in a plastic bottle and was filled with the water and the colour obtained is shown in a
plate / photo given in Annexure-III).
21
3. M/s Jubilant Agro & Consumer Products Ltd.,(Fertilizer unit)
01 Name of the industry & Complete Postal Address:
2 M/s Jubilant Agro & Consumer Products Ltd.,(Fertilizer unit) Bhartiagram, Gajraula, Distt: Jyotiba Phule Nagar – 244223,Uttar Pradesh
02 Name of Contact person with designation Phone & Fax No/Email:
C B Bhardwaj | Senior Vice President - Manufacturing (Unit Head) Mobile: 8126424555 FAX: 05924-252352
03 Year of commissioning 1982
05 Installed Capacity, TPA Sulphuric Acid-72000 TPA, Single Super Phosphate
Product & By product 1. Single Super Phosphate 2. Granulated SSP 3. Sulphuric Acid
07 Status of consents & Authorization (validity)
Sl. No. Consent under Validity Upto
1. Air Act 31.12.2017
2. Water Act 31.12.2017
3. Hazardous Waste. 03.03.2021
09 Raw material used / tonne of product
Raw Materials Sulphur, Rock Phosphate
Sources water
Ground Water through borewell (NOC obtained from CGWA on 7/4/2017 for 1400 KLD)
12 The waste water generated is recycled in the process
Observations :
4. M/s. Jubiliant Life Sciences Ltd. (Chemical Unit I)
01 Name of the industry & Complete Postal Address:
3 M/s. Jubiliant Life Sciences Ltd. (Chemical Unit I), Bharatigram, Gajraula, District – Amroha, UP
02 Name of Contact person with designation Phone & Fax No/Email:
C B Bhardwaj | Senior Vice President - Manufacturing (Unit Head) Mobile: 8126424555 FAX: 05924-252352
03 Year of commissioning 1982
05 Products & Installed
Capacity, TPA
Acetaldehyde - 246600TPA Formaldehyde – 140400TPA Acetic anhydride – 39000 TPA Ethyl Acetate – 89425 TPA Acetic Acid – 210300 TPA
Raw Materials, TPA Acetaldehyde- Ethanol-1.084 kl/MT Formaldehyde- Methanol – 0.42 MT/MT Acetic acid -1.227 MT/MT Ethyl acetate – Ethyl alcohol -0.73 KL/MT Acetic acid –Acetaldehyde -0.88 MT/MT
07 Status of consents & Authorization (validity) (Copy enclosed)
Sl. No. Consent under Validity Upto
4. Air Act 31.12.2018
5. Water Act 31.12.2018
6. Hazardous Waste. 15.12.2017
Total Water Requirement
2351 KLD (including Domestic water requirement 375 KLD) (Water balance flow diagram enclosed)
Sources water
Ground Water through borewell (NOC obtained from CGWA on 7/4/2017 for 2300 KLD)
Waste water generation 175 KLD goes to CETP
Effluent Treatment Plants:
Operational Status (during inspection):
22
Installed Treatment Capacity, (m3/day)
The wastewater generated from Chemical Unit – 1, and Polymer Plant are collected and treated at the Chemical Effluent Treatment Plant (CETP). The CETP of 700 KLD capacity was found operational. (CETP flow diagram enclosed)
ETP & Sequence of Treatment Plant: Process of the CETP are as follows: Acetyl Plant Equalization Tank (1 & 2) Reactivator Clarifier tank Aeration Tank 1 Sludge Clarifier tank Aeration Tank Sludge Clarifier Tank 2 Clarifier Water Tank Pressure Sand Filter (PSF) Activated Carbon Filter (ACF) Final Water Tank Cooling tower/Horticulture
5. M/s. Jubiliant Agri & Consumer Products Ltd. (Polymer unit)
01 Name of the industry & Complete Postal Address:
M/s. Jubiliant Agri & Consumer Products Ltd. (Polymer unit) Bharatigram, Gajraula.
02 Name of Contact person with designation Phone & Fax No/Email:
C B Bhardwaj | Senior Vice President - Manufacturing (Unit Head) Mobile: 8126424555 FAX: 05924-252352
03 Year of commissioning 1982
05 Products & Installed
Capacity, TPA
SPVA, PVA & Derivatives – 2458 MT/Month Wood finish – 450 MT/month Polyurethane & Derivatives
Raw Materials, TPA Soild PVA
Iso Propyl Alcohol
Vinyl Acetate Monomer
Di Iaurl Peroxide Wood Finish
Acetone
Xylene
Toulene
Ethyl Cellusolve
N Butanol
Ethyl Acetate
07 Status of consents & Authorization (validity)
Sl. No.
Consent under Validity Upto
1. Air Act 31.12.2017
2. Water Act 31.12.2017
3. Hazardous Waste. 15.12.2017
Total Water Requirement
250 KLD
Sources water
Ground Water through borewell (NOC obtained from CGWA on 7/4/2017 for 250 KLD)
Waste water generation 571 KLD goes to CETP
23
Effluent Sample Collected and analysis results
Locations pH TSS (mg/l)
COD (mg/l)
BOD (mg/l)
MLSS (mg/l)
CETP Inlet 3.26 142 2742 1732
CETP Outlet
8.12 21 125 28
Area ration Tank
- - - - 1445
Standards (Discharge on land)
200 250 100
Photographs
No over flow from Clarifier
Online flow meter installed at the CETP
Ash Pond filled up with garbage
24
Observations:
1. There is no MoU between the different units having individual consent to operate
for contribution/conveying their effluent to the CETP. Therefore, the primary raw
water quality will be subjective and meeting the norms will be a major challenge.
Apart from the operational difficulties, it is difficult to take any action by
the regulatory body in case on non-compliance observed to the stipulated
norms/ provisions as onus and obligation to meet the regulatory norms is not
clear.
2. The CETP was found operational during the visit. Water samples from the inlet,
outlet and aeration tank – I was collected to assess the performance. Results
suggests MLSS concentration to be in acceptable range.
3. The hydraulic gradient line of the CETP was non-continuous; an essential
parameter to support is proper functioning. It suggest there is a design and/or
poor maintenance issue.
4. The energy meter reading depicts the energy consumed; however, it is very
difficult to infer any conclusion on CETP operation status from the consumption
data, unless correlation of energy consumed and requirement is defined with a
7-day optimised operation of the CETP facilities.
5. The CETP is equipped with online effluent monitoring system and it needs to be
verified from the observed value during the field visit to assess the variation, if
any.
6. The treated wastewater is reported to be used for horticulture within the unit
area. There is no documentation / records maintained for the purpose. It needs
to be verified to ensure that there is no direct or in-direct discharge of such
treated water.
25
6. M/s. Jubiliant Life Sciences Ltd. (Chemical Unit II)
01 Name of the industry & Complete Postal Address:
M/s. Jubiliant Life Sciences Ltd. (Chemical Unit II), Bharatigram, Gajraula, District – Amroha, UP
02 Name of Contact person with designation Phone & Fax No/Email:
C B Bhardwaj | Senior Vice President - Manufacturing (Unit Head) Mobile: 8126424555 FAX: 05924-252352
03 Year of commissioning 1982
05 Products & Installed
Capacity, TPA
Pyridine -152 T/day Pyridine derivatives -30 T/day
Raw Materials, TPA Pyridine –Acetaldehyde 1.335 MT/MT, Formalin -2.57 MT/MT and Ammonia -0.49 MT/MT is consumed of pyridine production respectively.
07 Status of consents & Authorization (validity)
Sl. No. Consent under Validity Upto
1. Air Act 31.12.2018
2. Water Act 31.12.2018
3. Hazardous Waste. 15.12.2017
09 Raw material used / tonne of product
Raw Materials Sulphur, Rock Phosphate
Total Water Requirement
2632 KLD (including Domestic water requirement 30 KLD) (Water balance flow diagram enclosed)
Sources water
Ground Water through borewell (NOC obtained from CGWA on 7/4/2017 for 2600 KLD)
Waste water generation 571 KLD
12 Effluent Treatment Plants: MEE Incinerator Concentrate of 222 KLD is burned in the Incinerator , The condensate is recycled in the cooling tower
Observations: 1. The wastewater generated from these units are primarily non-biodegradable in
nature and cannot be subjected to conventional biological based effluent
treatment plant. The recalcitrant nature of wastewater is subjected to incineration
process.
2. As reported, 3 numbers of liquid incinerator (288 KLD) for management of such
wastewater has been provided.
26
7. M/s Insilco Ltd.,
A General Information & Production Details:
01 Name of the industry & Complete Postal
Address:
M/s Insilco Ltd., A-5 UPSIDC Industrial Area Bhartiagram, Gajraula, J. P. Naaar, UP, India
02 Name of Contact person with
designation
Phone & Fax No/Email:
Mr. Neeraj Arora
G.M. (Works) & Plant Head 05924-252830,
Mob. 08449718695 05924-252348
04 Date/Year of commissioning May, 1992
05 Product & Installed production capacity
(TPD) for each product
Precipitated Silica & 21,000 TPA
Presently operating at 16200TPA
Precipitated Silicon dioxide (Amorphous)
No By product
08 Raw material consumed
(Tons per ton of product)
Sodium silicate & Sulphuric acid
09 Total Water requirement (M3/day) Process 3500 KLD
Washing -
Domestic 8 KLD
Others (Specify) -
Total -
10 Sources of Water Bore Well Qty of Water is 4319 m3/day
(Avg. per day for first quarter Jan, Feb &
March - 2017) –
CGWA Permission – APPLIED
Separate Energy Meter Installed (log book copy provided)
B Waste Water – Generation & Treatment:
11 Wastewater generation, (M3/dav) As per consent Present status
Process effluent 6449 KLD 3900 KLD
Effluent Characteristics
Sampling
locations
pH TDS
(mg/l)
SAR SO4-
(mg/l)
F-
(mg/l)
Inlet 7.17 11112 27.7 5480 4.44
Outlet 7.64 320 6.4 55 0.41
Pond 7.13 10448 34.6 5932 3.92
Observations:
(i) This industry is involved in washing / processing of sand used in tyre industries.
(ii) The industry generates effluent having high Total Dissolved Solid (TDS).
(iii) At the time of inspection the effluent being discharged and the collected
outlet sample shows TDS of 320 mg/l. However when the samples were
picked-up from the Bagad river where the effluent is being disposed
indicated TDS of 11284 mg/l.
(iv) The Committee was deeply concerned after knowing that the industry is
using around 2 MLD of groundwater for diluting of effluent. The dilution
water is added with another chemical to reduce the SAT, which is not the
appropriate and acceptable approach to meet the stipulated norms of
prescribed SAR. Therefore, this industry should essentially to operate on
ZLD system and by recovery salt (Na2SO4) with any appropriate system.
In no case effluent be disposed in ambient environment.
27
8. M/S Kamakshi Papers (P) Ltd.
01 Name of the industry & Complete
Postal Address:
M/S Kamakshi Papers (P) Ltd., Industrial Estate, Delhi Road, Gajraula, Post – Bhartiyagam (Amroha) U.P. - 244223
02 Name of Contact person with
designation
Phone & Fax No/Email:
Raj Kumar Agrawal (Director)
8057900800
03 Year of commissioning August 1994
04 Category of Industry Medium
05 Installed Capacity, TPA Initially 20 TPD. Extended to 60 TPD in September,
2016. (21,600 MT) (Approx.) Trial Consent enclosed.
06 Energy required, KWH/MT Year 2016-17 2015-16 2014-15
1700 975 975
07 Status of consents & Authorization
(validity)
a. Air Consent: Up to 31-12-2016 (invalid) b. Water Consent: Up to 31-12-2016 (invalid) c. HW Authorisation: NA
08 Product manufactured in TPD/TPM/TPA
S.No. Product (grade/type) &
By Product
manufactured
Product manufactured in MTA
2016-17
(Up to Nov.
2016)
2015-16 2014-15
01 News print 3741.276 6032.97 5932.02
02 Writing printing
paper
1147.527 1187.06 671.108
09 Raw material used / tonne of product
S.No. Raw Materials Raw Material Consumption Per tonne of Product
2016-17 2015-16 2014-15
01 Waste paper
1.337
(Total 6534 TPA)
1.351
(Total 9754.315
TPA)
1.327
(Total 8760.659
TPA)
10 Process details with Material Balance:
Waste paper High consistency pulper Poir HD Cleaner Hole screen Decker
thickener Potcher washing Refiner Mixing chest Paper machine
Sources water
Ground Water through borewell (NOC obtained from CGWA on 21/3/2017 for 500 KLD)
11 Water Consumption & Waste Water Generated:
S.No. Water
Consumption,
KLD
Wastewater
Generated,
KLD
Water
Consumption
KL/MT of Paper
produced
01 Process 387.9 411.48 12.99
04 Domestic 5 -
12 Effluent Treatment facilities provided:
Fibre Recovery System Equalization Tank Primary clarifier aeration Tank
Secondary clarifer Irrigation
Sample collected form ETP analysed and results are:
Parameters pH TSS BOD COD
Inlet of ETP 6.77 761 113 474
Final treated effluent 6.90 58 52 222
Standards (as per
consent)
- 100 30 -
28
13
ETP sludge storage tank not managed Outlet of Secondary clarifier
Observations:
1. The unit is operating without valid consent as consent for trial run has been expired on
31.12.2016
2. The unit provided certain documents showing agreement with the farmers, who have
declared that they are using the treated wastewater from the Unit for agriculture purpose
and willing to take further water for a period 1st Jan to 31 Dec 2017. However, the
declaration does not provide information on the area of land and quantity required in
different months, thereby it seems that the provision is more of manage rather than intent
to utilise the treated wastewater.
3. It is therefore submitted that the unit is not a ZLD unit and there is enough scope for
discharge of treated wastewater to nearby environment, low lying area etc.
Recommendation
The unit shall obtain valid consent to operate from UPPCB before it start its operation
Water balance showing the potential of water reuse and fresh water consumption,
evaporation loss should be submitted to UPPCB. UPPCB shall considering the finding of the
water audit report issue necessary conditions in the consent operate.
Use of treated water for irrigation purpose shall not be treated as a route to achieve zero
discharge as there is no requirement on rainy days and in absence of any alternate option
of utilisation, the unit will be discharging to the ambient environment, n case they are
operational.
29
9. M/s Dairy India Private Ltd.
1. Name of the Unit and Address M/s Dairy India Private Ltd. Gajraula, Amroha, UP
2.
Name of Contact person with
designation
Phone & Fax No/Email:
V K Arora, Head, Corporate Governance
3. Installed Production Capacity: 125 KLD Milk Processing
4. Water Consumption 180 KLD
5. Source of water Ground water CGWA – Permission Awaited
6. Consent Status For Water Valid up 31/12/2017 For Air valid up 31/12/2017
ETP Samples analysis results
Sampling locations pH TSS (mg/l) COD (mg/l) BOD (mg/l)
Inlet 4.35 1700 5344 1025
Outlet 8.40 37 142 53
General discharge standards (Consented)
- 100 - 30
Observations The unit is not meeting the stipulated norms. The unit claim to have zero liquid discharge, through ferti-irrigation approach. Use of treated water for irrigation purpose shall not be treated as a route to achieve zero discharge as there is no requirement on rainy days and in absence of any alternate option of utilisation, the unit will be discharging to the ambient environment, in case they are operational.
Recommendation
UPPCB shall assess the water balance report of the industry and make necessary modification in the consent condition to have appropriate and feasible condition with objective to conserve ground water and save uncalled for discharge of treated effluent.
30
10. M/s. Kaushambi Papers Mills Pvt. Ltd.
1 Name of the Unit and Address M/s. Kaushambi Papers Mills Pvt. Ltd. Khasra No-138, naipura Kadar, The, Dhanaura, Gajraula, Amroha, UP
Operational status
The unit was found non-operational. As informed by the unit, due to mechanical line burst in Pulp mill, the unit shut down around 2 AM on 25/4/2017 i.e. on the same day of inspection.
Observations;
1. Waste was strewed around the campus, it is piled on the land claimed to be owned by the unit
2. Sludge is not properly stored and was found out side of the premisses also.
Recommendations: The unit shall manage the litter and scattered solid waste in proper and secured system. A proper action plan with time target for storage in a secured land fill /or any acceptable disposal mechanism to UPPCB shall be submitted by the units to UPPCB, before it is allowed to operate.
31
Annexure -II
Units visited by the Officers of CPCB, UPPCB, MoWR on 01/05/2017
7. TEVA API Limited, Gajraula
1. The Unit was operational during visit.
2. The Unit has two bore well with water meter installed at a distance of 200m metre from
the bore well.
3. The Unit has valid consent under Water/Air and HW Rules valid upto 31.12.2017.
4. STP. There are two STPs of 100 KLD (under stabilisation) and 60 KLD (operational).
The STP is receiving wastewater from colony as well as domestic sources of industrial
area. However, there is no flow measurement device at the inlet & outlet to measure
the quantity of effluent generation. STP treated effluent is partially fed in gardening
and partially mixed with ETP treated waste prior polishing RO for further treatment.
5. ETP. The ETP was operational and comprise of activated sludge process followed RO
treatment and concentration and incineration of RO Reject through MEE/ MVRE and
ATFD / Spray Dryer. ETP treated effluent (final RO permeate) is used as make up
water for cooling tower. Sample of RO permeate was taken for analysis and result is
awaited.
6. Dedicated energy meter was installed for the ETP electrical consumption, however the
energy meter was installed far from ETP, therefore needs to install within the ETP.
7. During inspection no discharge was found outside the premises. The Unit should not
provide multiple outlet for the storm water drain. The 3 outlets for storm water drain
was regulated by valve and pumps which was found locked during visit. The Unit
informed that the pumps are used to take first ‘10 minutes’ storm water into the ETP.
However, the records of operation of valves and pumps are no available.
8. The Unit has installed real-time OCEMS and connected to CPCB server and
Calibrated by supplier/forbes Marshell. During visit it was operational.
9. Analytical results will be ready by 05.05.2017 and will be processed
8. M/s Umang Dairy Ltd, Gajraula
1. The Unit was closed during visit.
2. The Unit as consent valid upto 31.12.2017 under Water/Air and HW Rules.
3. The Unit has 3 bore wells for ground water abstraction and has installed water meter
with logbooks.
4. Sewage treatment. The Unit has septic tank for the colony and industrial sewage
wastewater.
5. ETP is based on ASP process followed by RO/UF treatment process.
32
6. ETP was operational for stabilising the biomass in aeration tank so that the plant can
handle raw effluent at any time.
7. The RO Reject (262 KLD) is diluted with freshwater (500 KLD) and mixed effluent is
used for planation/land application (10 acres). The unit shall discontinue the process of
dilution of RO reject for disposal of RO reject.
8. CGWA permission under process and RO, CGWA has recommended for NOC.
9. Dedicated energy meter was installed for the ETP.
10. Flowmeter ware installed at the inlet & outlet of ETP.
11. Camera and flowmeter were installed at the ETP, however the Unit is not a ZLD plant,
therefore needs to install real-time OCEMS for pH, BOD, COD, TSS parameters as per
the CPCBs directions.
12. Closed.
9. M/s Coral News Print Ltd., Gajraula, UP
1. The unit was Closed at the time of inspection. As informed by industry the production
was stopped since 29th April, 2017.
2. The Unit Consent under Water & Air Act expired on 31.12.2016, however has applied
for the renewal.
3. No ‘Authorization’ has been obtained under Hazardous Waste Management Rule from
UPPCB for disposal of ETP sludge & used oil etc.
4. The aeration tank of ETP was found operational to stabilize the biomass so that the
plant can handle effluent at any time.
5. The Unit have only hill screen to recover the fiber reaching the ETP.
6. Sign of overflow from sludge drying bed observed, capacity of drying beds required to
be increased.
7. The sludge press machine is not maintained properly and reflects that it is not being
used for past one month or so.
8. No tertiary treatment (Sand filter/ multi-media filter/ACF) facility found in ETP. As per
the Charter programme (pulp & paper) in Ganga basin States, industries are required
to install tertiary treatment system.
9. The Unit has installed is ‘V’ shaped Notch (flow measurement) at the inlet of ETP &
online effluent monitoring system (OCEMS) at final discharge line and connected to
CPCB server.
10. The location of OCEMS & placement & one of its probe seems improper as the probe
placed just above the bottom of a pit on the outlet drain. After the OCEMS also, the
outlet drains receives water along with fly-ash from boiler area.
33
11. A Sample from treated water holding tank was taken for analysis and to assess the
need for tertiary treatment and results is awaited.
12. The Unit needs to conduct ground water monitoring to know the impact of effluent
through land application.
13. Closed.
34
Annexure –III
Color of the ground soil (where compost / spent was and soil was mixed ) when mixed
with Water
35
Compiled status of specific information as desired Hon’ble NGT of 10 industrial units
S. No. 1 2 3 4 5 6 7 8 9 10
Name of the Units/
Specific information required
M/s ASP
Sealing Product
Ltd.,
Gajraula
M/s. Jubiliant Agri &
Consumer Products Ltd.
(Fertilizer
Unit) Bharatigram,
Gajraula, District –
Amroha,
M/s. Jubiliant
Life Sciences Ltd. (Chemical
Unit I),
Bharatigram, Gajraula,
District – Amroha,
M/s. Jubiliant Life Sciences
Ltd. (Chemical Unit II).
Bharatigram,
Gajraula, District – Amroha,
M/s Jubiliant
Life Sciences Ltd. (Distillery
Unit),
Bharatigram, Gajraula,
District – Amroha,
M/s. Jubiliant Agri &
Consumer Products Ltd.
(Polymer unit)
Bharatigram, Gajraula.
M/s Dairy India
Private
Ltd. Gajraula,
Amroha,
M/s Insilco Ltd.,
A-5, UPSIDC
Industrial Area, Gajraula,
M/s.
Kaushambi Papers Mills
Pvt. Ltd.Khasra
No-138,
naipura Kadar, Dhanaura,
Gajraula,
M/s. Kamakshi Papers Pvt. Ltd.
Gajraula
1
What is the source of water used by the
industry and its quantity, availability,
water meters etc.?
Ground
water
(24 KLD)
Ground Water Water meter
installed (1400 KLD)
Ground Water Water meter
installed
(2300 KLD)
Ground Water Water meter
installed (2600 KLD)
Ground Water Industrial-
(3000 KLD)
Ground Water (250 KLD)
Ground water
Ground Water 4319 m3/day
Ground Water Ground Water (500 KLD)
2
Whether the unit are ZLD, ZLD means they
are not discharging any effluent, either on the
land or in the waterbody
or at any other place for that matter. They
should be able to either not discharge a drop of
liquid or recycle the same entirely without
releasing thereto any
effluent.
Not ZLD ZLD unit, there is no
ETP processing
water is being
recycled and reused
(Non-operational)
Treated effluent being
used for horticulture
(Unit
mentioned)
Treated effluent being used for
horticulture (Unit
mentioned)
ZLD unit Recycle and
reused water
Not ZLD Recycle and
reused water
Not ZLD Use for
irrigation
Not ZLD unit
Having Consent to discharge
Not ZLD (Operational)
Not ZLD Recycle and
reused
3
Whether adequate ETPs
have been provided and
were found to be functional or not at the
time of inspection, including its adequacy;
ETP Not
available
Not ETP
provided
Chemical ETP
found
operational (Unit 1 &
Polymer)
Incilater Not applicable Chemical ETP
found
operational (Unit 1 &
Polymer)
ETP
operation
al
Yes
ETP is adequate
& found operational
(Performance)
ETP found
operational
ETP found
operational
36
S. No. 1 2 3 4 5 6 7 8 9 10
Name of the Units/
Specific information required
M/s ASP
Sealing Product
Ltd., Gajraula
M/s. Jubiliant Agri &
Consumer Products Ltd.
(Fertilizer
Unit) Bharatigram,
Gajraula, District –
Amroha,
M/s. Jubiliant
Life Sciences Ltd. (Chemical
Unit I),
Bharatigram, Gajraula,
District – Amroha,
M/s. Jubiliant
Life Sciences
Ltd. (Chemical Unit II).
Bharatigram, Gajraula, District
– Amroha,
M/s Jubiliant
Life Sciences Ltd. (Distillery
Unit),
Bharatigram, Gajraula,
District – Amroha,
M/s. Jubiliant
Agri &
Consumer Products Ltd.
(Polymer unit) Bharatigram,
Gajraula.
M/s Dairy India
Private
Ltd. Gajraula,
Amroha,
M/s Insilco Ltd.,
A-5, UPSIDC
Industrial Area, Gajraula,
M/s. Kaushambi
Papers Mills
Pvt. Ltd.Khasra
No-138, naipura Kadar,
Dhanaura,
Gajraula,
M/s. Kamakshi Papers Pvt. Ltd.
Gajraula
performance; and its records thereof.
4
The Committee would collect effluent samples
at the inlet and outlet of
the ETP and at the point of discharge, at the
ultimate end.
From holding
tank
Not applicable Sample collected
Sample collected Sample not Collected
Sample collected
Sample collected
Sample collected
Industry was closed at the
time of
inspection
Sample collected
5
Whether there is
separate provision of
Energy Meter for the ETP/ZLD.
Not
aplicable Not applicable Yes - Yes
Yes Yes
Yes
6
Whether there are
online monitoring system installed and
operative and if so connected to which
authority, calibration/validation
thereof;
Not
installed
Common
OCEMS installed
- - Yes, OCEMS
installed
Yes, OCEMS
installed
- OCEMS
Not installed
Yes, OCEMS
installed
Yes, OCEMS
installed
7
Whether water flow-meter have been
installed.
yes Yes Installed at outlet of ETP
Installed at outlet of ETP
Yes Yes
Provided V-Notch &
Calibration
chart
N/A Yes
37
S. No. 1 2 3 4 5 6 7 8 9 10
Name of the Units/
Specific information required
M/s ASP
Sealing Product
Ltd., Gajraula
M/s. Jubiliant Agri &
Consumer Products Ltd.
(Fertilizer
Unit) Bharatigram,
Gajraula, District –
Amroha,
M/s. Jubiliant
Life Sciences Ltd. (Chemical
Unit I),
Bharatigram, Gajraula,
District – Amroha,
M/s. Jubiliant
Life Sciences
Ltd. (Chemical Unit II).
Bharatigram, Gajraula, District
– Amroha,
M/s Jubiliant
Life Sciences Ltd. (Distillery
Unit),
Bharatigram, Gajraula,
District – Amroha,
M/s. Jubiliant
Agri &
Consumer Products Ltd.
(Polymer unit) Bharatigram,
Gajraula.
M/s Dairy India
Private
Ltd. Gajraula,
Amroha,
M/s Insilco Ltd.,
A-5, UPSIDC
Industrial Area, Gajraula,
M/s. Kaushambi
Papers Mills
Pvt. Ltd.Khasra
No-138, naipura Kadar,
Dhanaura,
Gajraula,
M/s. Kamakshi Papers Pvt. Ltd.
Gajraula
8
The inspection team shall also analyse the
effluent quality at the end of the drain as well
as at the point where
Mahua starts.
Team could not visit due to time constraint
9
The samples shall also
be collected from the drain nearest to the
industrial unit.
Sample was collected from the Bagad River
10 The committee may also examine the Ambient
Air Quality in that area.
Team could not visit due to time constraint
11
Whether any of the industries have a by-
pass mechanism provided in the factory,
even if it has been now
closed or groundwater injection system.
Could not found
By-pass arrangement
available (CPCB issued
show cause
notice on 13.01.2017)
12
The inspection shall also
verify the agriculture areas used for disposal
of effluent of the industries.
Visited & sample collected
****